Category Archives: Procedures

3 Tips for a Successful USCG Inspection

Many companies aren’t prepared when they receive a letter from the U.S. Coast Guard notifying them of an upcoming facility security inspection. You might have documents that are out of date, or you may be missing the necessary forms. If left unchecked, you could be forced to waste time and money in enforcing corrective actions. When it comes to advising our clients to be prepared, these are the top three tips we give them for a successful USCG Inspection.

Review Your Documents

When you receive a notice from the USCG about an upcoming inspection, this is always a good time to review your FSP and required documents to make sure that you have everything in order. Also, this is a good time to verify that you have conducted the required quarterly drills, annual exercise, and annual audit of the FSP.

Training Moment

Training is very important for facility personnel and this is a good opportunity to make sure all your training is up to date and to have a general discussion regarding security of the facility. The training can focus on topics that will most likely be covered during the inspection; including TWIC, screening, security personnel (who is the FSO, Alt. FSO?), MARSEC security measures, etc.

Organize

One thing that we recommend and develop for majority of our clients is to have a single security plan binder with all relevant documents and forms. This is a perfect, centralized place to store and secure all the forms and documents that the USCG will want to review during the inspection. We have had great success with these binders for all of our regulated clients; MTSA, CFATS, TSA, DOT, etc. As we tell our clients, it is best to get the inspectors the requested material in a timely fashion and get the inspection over with as quickly as possible.

Recently one of our clients had a US Coast Guard inspection that they passed without any issues, “We went through our MARSEC book while the USCG was here and we were complimented on how all the files for MARSEC were in one book and not in different locations.  We didn’t spend much time with it, because everything was in the binder that they had questions about. “

Let us know if we can help you prepare for USCG Security Inspection and develop a security binder for you and help you succeed with your inspections.

Policy Procedures and Standards Made Simple

As a public safety officer, I was once tasked with writing instructions for loading pre-connected hose lines on fire trucks.  While a straight forward task, a mistake or simple misunderstanding by a firefighter could have serious consequences, delaying rescue and/or getting water on the fire. Writing clear step by step procedures was a challenge and also great training, especially when the procedures would be tested on the fire academy training ground.

I have been engaged in policy and procedure development for security, safety, environmental, and chemical management functions since 1981.  I believe I have learned a few things:

Clarity and Enforceability – keep it simple and straight forward, not only to help employees understand the rules and guidelines, but to enable enforceability for violations of company policy, a key concern today of Human Resources.  How well will the policy stand up in court?

Consistency in Format and Template – Following a consistent template for all policy and procedures makes it easy for employees to find the information they need and enhances their understanding of requirements.

The Distinction between Policy, Procedure, Standard and Guideline.

Definitions based on NIST (National Institute of Standards and Technology) and SANS Institute standards include:

  • Policy – A policy is a system of principles to guide decisions and achieve rational outcomes. A policy is a statement of intent, and is implemented as a procedure or protocol.   Policy is generally drafted to foster enforceability.
  • Procedure – A set of business processes, activities and tasks that, when implemented, contribute to accomplishing a policy goal. Procedures are often step by step instructions and are drafted to be enforceable.
  • Standard – A document that provides requirements, specifications, or characteristics that can be used consistently to ensure that materials, products, processes and services are fit for their purpose. Often a minimum standard that must be followed.
  • Guideline – Recommended practice that allows some discretion or leeway in its interpretation, implementation, or use.

The Policy Catalogue – How does a company make it easy for employees to find the policy and procedures they need?  During a project last year, we conceived the idea of a “Policy Catalogue”, a well indexed online document that contained all IT policies and the subordinate procedures, standards, and guidelines for each policy.  The catalogue Table of Contents, in one quick glance, showed not only where to find what was needed, but how the whole policy system was organized.

Don Greenwood & Associates, Inc. has an extensive library of asset protection and security policies and procedures, as well as model security standards, manuals, and post orders.  We also have a well catalogued collection of IT governance and IT security policy, procedures and standards.  For procedure review and development ideas, contact us at don@greenwoodsecurity.com.